In November 2025, the International Trade Union Confederation (ITUC) submitted its recommendations to IFC regarding Performance Standards PS1 and PS2, calling on IFC to strengthen its human rights due diligence, worker protections, stakeholder participation, transparency, and health and safety requirements, in line with modern international human rights and labor frameworks. You can read the full submission here.

Key points include:

  • Continuous stakeholder engagement:
    PS1 should ensure stakeholder engagement is a continuous and iterative process throughout the entire project lifecycle, so that affected communities and workers can participate in identifying, preventing, mitigating, and remedying harms.

  • Alignment with international due diligence standards:
    PS1 should be updated to reflect frameworks such as the UN Guiding Principles on Business and Human Rights, OECD Guidelines for Multinational Enterprises, and the ILO MNE Declaration.

  • Early worker engagement in high-risk projects:
    The proposal recommends mandatory negotiated agreements with legitimate worker representatives before financing, shifting IFC practice from reactive remediation to proactive human rights risk prevention.

  • Strengthening labor protections:
    Updates should address employer obligations, protections against gender-based violence and harassment (following ILO Convention 190), stronger trade union and freedom-of-association rights, and better safeguards for supply-chain workers and migrant workers.

  • New Occupational Safety and Health (OSH) standard:
    OSH is currently covered minimally in the IFC standards. The proposal suggests creating a standalone OSH standard, modeled on policies used by other multilateral development banks (e.g., EBRD), especially after the ILO recognized a safe and healthy working environment as a fundamental labor right.

  • Improved transparency and disclosure:
    The IFC’s Access to Information Policy allows projects to be disclosed too late—sometimes after approval or even after funds are disbursed. The recommendation is to limit delayed disclosure to legal/regulatory cases, release information earlier, and remove “market conditions” as a justification for delays.

  • Stronger safety exclusions:
    The IFC’s current policy still allows certain asbestos-containing cement products (<20% asbestos). The proposal recommends banning all asbestos, aligning with policies already adopted by other development banks.

You can read the full submission here.